President-Elect's Stimulus and Vaccine Plans. Late last week, President-Elect Joe Biden announced his proposals for a $1.9 trillion stimulus plan and for COVID-19 vaccinations. Unfortunately, the stimulus proposal does not include any additional appropriation for the Provider Relief Fund (PRF), which will contain approximately $23 billion after all planned distributions are made. While the President-Elect called for $350 billion in funding for state and local governments, none of it appears to be in the form of a further increase or extension of the current enhanced federal Medicaid funding. The proposal, however, contains the following statement: "The president-elect’s proposal provides critical funding for states to deploy strike teams to long-term care facilities experiencing COVID-19 outbreaks--which may impede vaccination of residents and workers--and to conduct better infection control oversight." The vaccination plan, the key aspects of which also appear in the stimulus proposal, focuses mainly on increasing availability of vaccine and recruiting 100,000 health professionals to administer shots. Athough no detail are provided, the plan specifies, "[t]he administration will make programs available for high-risk congregate settings, including homeless shelters, jails, and institutions that serve individuals with intellectual and developmental disabilities."
Updates to PRF FAQs. The Department of Health and Human Services (HHS), in conjunction with the announcement that it is opening a Reporting Portal for the PRF, but only for registration, and delaying the previously-announced February 15, 2021, reporting deadline, also updated its general PRF frequently-asked questions (FAQs). The changes, dated January 15, confirm the reporting delay. They also address questions about "missing" Phase 2 General Distribution payments (see page 36), explaining:
Many applicants that believe that their organization has not yet been paid under Phase 2 have received funds that can only be accessed after setting up an Automated Clearing House (ACH) account. Organizations with revenue greater than $5,000,000 are required to set up ACH accounts to allow the Department of Health and Human Services (HHS) to most effectively and quickly deliver funds to providers, as well as maximize program integrity and fraud avoidance. For assistance in setting up an ACH account, please contact the Provider Support Line at (866) 569-3522 (for TTY, dial 711).
Other applicants may have received Phase 2 funds in November or December that the applicant believes were part of Phase 3 of the General Distribution. Additionally, HHS has requested that a small number of applicants resubmit their application and financial information for data verification. In some instances, HHS has not received the requested resubmissions, and therefore, cannot adjudicate those applications.
In addition, HHS issued a separate set of FAQs on the Reporting Portal. The FAQs clarify that recipients of SNF Infection Control Distributions must register, even though HHS has not published reporting requirements for them, and that registrants do not use their Optum identification to register. The FAQs list the information needed to complete the registration, which includes the payment amount. At this time, there is no deadline for registering. The 6-page FAQs address a number of other issues about registration and reporting, including how companies with multiple entities that received payments should register, so all PRF recipients should review them.
CMS Approves Appendix K Extension. Last Friday afternoon, the Centers for Medicare and Medicaid Services (CMS) approved Ohio’s request to extend the state's Appendix K waiver flexibility document. This approval allows the temporary flexibilities in the existing Appendix K to stay in place for up to six months after the end of the Public Health Emergency (PHE). The current PHE is set to expire April 20, 2021, which unless it is extended again, would set the Appendix K expiration date at October 20, 2021. As shared previously, Ohio, on behalf of the Department of Developmental Disabilities, now will submit an amendment to the just-approved Appendix K requesting authority to issue a lump-sum payment to ID/DD waiver providers to assist with increased costs from the PHE. OHCA will keep ID/DD members updated on the status of the new Appendix K request as we receive additional information.
ODH Information for Vaccine Providers. The Health Department (ODH) continues to issue important materials for enrolled vaccine providers, including guidance on submitting their location, temperature monitoring standards, directions and codes for reporting a vaccine recipient's population group or occupation, and the actual vaccination registration form that must be completed for each person immunized.
Please note that OHCA is presently in conversation with state officials about how additional Phase 1A individuals (e.g., new admissions to a congregate facility) should be vaccinated and the respective roles of facilities and long-term care pharmacies as vaccine providers in the state's system.